ML18153B916
| ML18153B916 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/02/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-668, NUDOCS 8910110134 | |
| Download: ML18153B916 (7) | |
Text
.JI.
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 2, 1989 United States Nuclear Reg'ulatory Commission Attention:
Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION Serial No.:
SPS/GDM/pmk Docket Nos. :
License Nos.
NRC INSPECTION REPORT NOS. 50-280/89-21 AND 50-281/89-21 89-668 Rev. E 50:.280 50-281 DPR-32 DPR-37 We have reviewed your letter dated September 1, 1989, in r~ference to the NRC i_!lspection conducted from July 2-29,
- 1989, fo.r Surry Power Station.
The inspection was reported in Inspection Report Nos.
50-280/89-21 and 50-281/89-21.
Our response to the violations described in the Notice of Violation is provided in the Attachment.
We have no objection to this inspection report bein9 made a matter of public disclosure.
If you have.any further questions, please contact us.
Very truly yours, J5/f,(._
j,ll.,,w L. Stewart enior Vice President - Power cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N~W.
Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Sta ti on 8910110134 891002 PDR ADOCK 05000280 G
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Attachment Reiponse to Notice of Violation Reported During the NRC Inspection From July 2~29, 1989 Inspection Report Nos. 50/280-89-21 and 50/281/89-21 NRC Comment:
During the Nuclear Regulatory Commission (NRC) inspection conducted between the period of July 2-29, 1989, violations of NRC requirements were identified.
In accordance with the 11General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2, Appendix C (1989), the violations are listed below:
A.
Technical Specification 6~4 requires detailed -written procedures with appropriate checkoff 1 i sts and instructions sha 11 be provided and fo 11 owed for calibration of components involving the nuclear safety of the station.
Contrary to the above, on July 9, 1989, detailed written procedures and/or instructions were not provided in that incorrect calibration equipment was used to adjust the flux trip setpoint on the Unit 1 power range nuclear instrumentati-on channel N41.
Use of the incorrect instrument resulted in a blown fuse ~nd subsequent transient causing an automatic reactor trip from approximately 30 percent power.
This violation is a Severity Level IV violation (Supplement I).
B.
Technical Specification Table 3.7-2, Item 5.a requires that an inoperable low intake canal level channel be placed in trip within one hour after the channel becomes inoperable.
Contrary to the above, on July 14, 1989, stop logs were installed between the channel I I I rendering the required until inoperable.
low intake canal level instrument and the intake canal channel inbpetable.
The channel ~as not placed in trip as approximately seven hours after the instrument became This violation is a Severity Level IV violation (Supplement I).
. C.
Technical Specification 3.6.B.2 requires that a minimum of 60,000 gallons of water shall be available in the tornado protected condensate storage tank of the opposite unit to supply emergency water to the auxiliary feedwater pump suction of that unit.
Contrary to the above, on July 27, 1989, the Unit 2 emergency condensate storage tank (2-CN-TK-l) contained only approximately 50,000 gallons of water for approximately 4 and 1/2 hours due to operator error.
During this
- time, Unit 1 was operating at power requiring the quantity of water specified above to be available.
This violation is a Severity Level IV violation (Supplement I).
Response to Notice of Violation
- Inspection Report Nos. 50-280/89-21 and 50-281/89-21 Violation A-
. RESPONSE:
(1) Admission or Denial of the Alleged Violation:
The violation is correct as stated.
(2)
Reasons for Violation:
(3)
(4)
During preparation efforts to rescale the power range detectors by the station instrument technicians, a concern was identified by the technicians and their supervisor as to whether to use a grounded or ungrounded voltmeter.
However, detailed instructions were not given to the technicians prior to starting the job.
As a result, the wrong meter was used which resulted in a turbine runback du~ to a blown fuse~
Corrective Steps Which Have Been Taken and the Results Achieved:
Instrument ~epartment technicians have been instructed on the proper use of grounded/ungrounded test equipment.
The technicians have also been directed to ensure any concerns are clearly resolved prior to proceeding with a job assignment.
In-house and operating experience review reports involving the misuse of test equipment were reviewed and incorporated into a lesson plan taught to the, instrument technicians during the third quarter of conti~uing training.
This training was completed on September 7, 1989.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
The instrument technician development training program is being revised to include instruction on the use of grounded/ungrounded test equipment and review of in-house and operating experience review reports involving the misuse of test equipment and the lessons learned.
(5)
The Date When Full Compliance Will Be Achieved:
Full compliance will be achieved upon completion of the rev1s1ons to the instrument technician development program which will be accomplished by January 31, 1990.
Violation B
RESPONSE
Response to Notice of Violation Inspection Report Nos. 50-280/89-21 AND 50-281/89-21 (1)
Admission or Denial of the Alleged Violation:
The violation is correct as stated.
(2)
Reasons for Violation:
The cause of the event was personnel error. Operations personnel did not identify the applicable operations procedures that required revision during their portion of the design change technical review process.
In
- addition, operators failed to recognize that installation of stop logs on the unit in cold shutdown isolated a canal level channel on the operating unit.
Stop logs were installed in the Un~t 2 intake structure which was not in operation at the time.
This resulted in inadequate consideration during the review of the safety consequences of the stop log installation.
The Temporary Modification (TM) procedure requires a review of the need for a safety analysis if the modification will make an inoperable system operable* or is installed on an operable system.
The modification was interpreted as not meeting these requirements and the need for a safety analysis was not reviewed.
(3)
Corrective Steps Which Have Bee~ Taken and the Results Achieved:
The stop logs were removed from the Unit 2 intake structure on July 17, 1989 and the affected level channel was restored to normal operation.
Every TM is now screened to determine if a 10CFR50.59 review/safety analysis is required.
Also, the Shift Technical Advisors are required to review the TMs for concurrence.
The Superintendent of Operations has met with each Shift Supervisor and with each shift and discussed this event.
He has also issued a memorandum to operations personnel reminding them of additional systems/components from one unit which are required to be available for the opposite unit.
A Human Performance Evaluation System (HPES) report has been prepared for this event, which includes corrective action recommendations to preclude a similar event.
These actions include the following:
- 1)
Revise the Temporary Modification administrative procedure to ensure potential effects on the opposite unit are considered,
- 2)
Place the Licensee Event Report for this incident in operator required
- reading,
- 3)
Implement procedures for th~ installation of stop logs at the high level intake structure, and
- 4)
Revise the startup checklists to evaluate the installation of a stop log to determine if jt could affect the operability of any system required by technical specifications prior to exceeding the operating mode for which the system is required.
Pursuant to the HPES recommendations and management direction, Maintenance Operating Procedures have been written and implemented for the installation of stop logs at the high level intake structures. Also, the pre-startup checklists have been revised.
The checklists now require a review of the status of stop 16g installatio~ on. both units to ensure that systems required to be
- operable by Technical Specifications in a particular mode will not be affected.
The LER for this event has been placed in operator required reading as well.
(4)
Corrective Steps Which Will Be Taken to Avoid Further Violations:
The TM procedure will be rewritten to incorporate an enhanced review process which will consider the effects that a TM may have on a system or component of the opposite unit.
(5) lhe Date When F~ll Compliance Will Be Achieved:
The requfred action items have been completed except for the upgrade of the TM-procedure.
This procedure revision is scheduled for comp_letion by December 31, 1989.
Ji Violation C
RESPONSE
Response to Notice of Violation Inspection Report Nos. 50-280/89-21 and 50-281/89-21 (1)
Admission or Denial of the Alleged Violation:
The violation is correct as stated.
(2)
Reasons for Violation:
The cause of the event is personnel error.
The licensed reactor operator involved with the event failed to recognize that a T.S. minimum of 60,000 gallons of water was required to be maintained in the Emergency Condensate Storage Tank (ECST) for cross connect availability for the opposite.unit.
(3)
Corrective Steps Which Have Been Taken and the Results Achieved:
The personnel involved were disciplined.
A procedure has been written to perform the evolution of transferring water from the ECST to the underground storage tank using a simplified method.
Additional procedures are being enhanced to more clearly identify ECST volume requirements.
A Human Performance Eva 1 uati on System ( HPES) report has been prepared for this* event which includes corrective action recommendations to preclude a similar event.
These actions include an engineering evaluation of possible annunciator enhancements and implementation of pre-job briefings for proceduralized evolutions on safety related systems.
The Senior Vice President - Power has met with each onshift SRO to discuss attention to detail.
The Superintendent of Operations has issued a memorandum to operations personnel reminding them of the systems/components from one unit which are required to be available for opposite unit operations.
(4)
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The HPES reports corrective action.recommendations are presently being implemented by the appropriate departments.
Since the present Technical Specification does not specifically address a time period during which the opposite unit 1s ECST may be inoperable, for consistency, a Technical Specification change is being prepared.
This change will allow the opposite unit 1s ECST to be inoperable during the same time period for the opposite unit 1 s Auxiliary Feedwater piping, valves and control board indication.
(5)
The Date When Full Compliance Will Be Achieved:
Full compliance will be achieved upon completion of the HPES recommendations.
These activities w,-11 be completed by January.31, 1990.
The Technical Specification change will be submitted to the NRC by October 31, 1989.